Section 263 Enquiry Threshold

In a revisionary proceeding, the Tribunal affirmed that an assessment order passed without meaningful inquiry into a high-value transaction is both erroneous and prejudicial to the interests of the Revenue. 

The failure of the Assessing Officer to examine the substance of a business transfer masked as professional goodwill justified invocation of Section 263. The ruling reinforces that absence of inquiry, not merely incorrect conclusion, is sufficient to trigger revision.